statement of basis/proposal plan for west of savannah river …/67531/metadc742521/... · fields...

006641

United States Department of Energy

Savannah River Site

Statement of Basis/Proposed Plan for the West ofSavannah River Ecology Laboratory (SREL) GeorgiaFields Site (631 -19G) Operable Unit (U)

WSRC-RP-99-4163

Revision 1

February 2000

Prepared by: # .slslml, rk

Westinghouse Savannah River Company LLC“Oe

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““”SK*.A

Savannah River Company.

Aiken, SC 29808 8A VANNAH RIVER SITE

Prepared for the U.S. Department of Energy under Contract No. DE-AC09-96-SR18500

This document was prepared in conjunction with work accomplished under Contract No.DE-AC09-96SR18500 with the U. S. Department of Energy.

DISCLAIMER

This report was prepared as an account of work sponsored by an agency of the United StatesGovernment. Neither the United States Government nor any agency thereof, nor any of theiremployees, makes any warranty, express or implied, or assumes any legal liability or responsibilityfor the accuracy, completeness, or usefulness of any information, apparatus, product or processdisclosed, or represents that its use would not infringe privately owned rights. Reference herein toany specific commercial product, process or service by trade name, trademark, manufacturer, orotherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring bythe United States Government or any agency thereof. The views and opinions of authors expressedherein do not necessarily state or reflect those of the United States Government or any agencythereof.

This report has been reproduced directly from the best available copy.

Available for sale to the public, in paper, from: U.S. Department of Commerce, National TechnicalInformation Service, 5285 Port Royal Road, Springfield, VA 22161,phone: (800) 553-6847,fax: (703) 605-6900email: [email protected] ordering: http://www.ntis.gov/help/index.asp

Available electronically at http://www.osti.gov/bridgeAvailable for a processing fee to U.S. Department of Energy and its contractors, in paper, from: U.S.Department of Energy, Office of Scientific and Technical Information, P.O. Box 62, Oak Ridge, TN37831-0062,phone: (865)576-8401,fax: (865)576-5728email: [email protected]

006641

CERTIFICATION

West of SREL Georgia Fields Site Operable Unit (631 -19G)

Statement of Basis/Proposed Planfor the West of SREL Georgia Fields Site Operable Unit (631 -19G) (U)

WSRC-RP-99-4163, Revision 1, February 2000

“I certifi under the penalty of law that this document and all attachments were prepared undermy direction or supervision in accordance with a system designed to assure that qualifiedpersonnel properly gather and evaluate the information submitted. Based on my inquiry of theperson or persons who manage the system, the information submitted is, to the best of myknowledge and belief, true, accurate, and complete. I am aware that there are significantpenalties for submitting false information, including the possibility of fines and imprisonment for&owing violations.”

Date: %?%!%) Signature:

Vice President and General ManagerEnvironmental Restoration DivisionWestinghouse Savannah River CompanyCo-operator for the U.S. Department of EnergySavannah River Operations Office

U.S. Department of EnergySavannah River Operations OfficeOwner and Co-operator

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SB/PP for the West of SREL Georgia Fields Site (631 -19G) OU (U) WSRC-RP-99-4163Savannah River Site Rev. 1February 2000 Page iii of vi

TABLE OF CONTENTS

LIST OF FIGURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .........."""."""."". . .111

LIST OF ACRONYMS AND ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv

SECTTON I.

SECTION II.

SECTION III.

SECTION IV.

SECTION V.

SECTION VI.

SECTION VII.

SECTION VIII.

SECTION IX.

SECTION X.

REFERENCES

GLOSSARY

INTRODUCTION AND BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

COMMUNITY PARTICIPATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

OPERABLE UNIT BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION . . . . . . . . . . . . . . . . . . . . 10

SUMMARY OF SITE RISKS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

REMEDIATION OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

SUMMARY OF ALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

EVALUATION OF ALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

PREFERRED ALTERNATIVE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

POST-ROD SCHEDULE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..................... 13

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..................... 13

FIGURE 1.

FIGURE 2.

FIGURE 3.

LOCATION OF THE WEST OF SREL GEORGIA FIELDS SITE (631 -19G) OPERABLE UNIT ATTHE SAVANNAH RIVER SITE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2BOUNDARY OF THE WEST OF SREL GEORGIA FIELDS SITE (631 -19G) OPERABLE UNITAND LOCATION OF SURFACE SAMPLES, SOIL BORINGS AND DEBRIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6CONCEPTUAL SITE MODEL FOR THE WEST OF SREL GEORGIA FIELDS SITE (631 -19G)OPERABLE UNIT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

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ARAR

bls

BR4

CERCLA

cm

CMCOC

CocCSM

DCE

DQO

FFA

ft

GFS

ha

HSWA

in

km

m

MCL

mg/kg

mi

NPL

OuPCB

RBcRCRA

RFI

RI

RME

ROD

SBiPP

SCDHEC

LIST OF ACRONYMS AND ABBREVIATIONS

applicable or relevant and appropriate requirement

below land surface

baseline risk assessment

Comprehensive Environmental Response, Compensation, andLiability Act 1980

centimeter

contaminant migration constituent of concern

constituent of concern

conceptual site model

tram -1, 2-dichloroethene

data quality objective

Federal Facility Agreement

feet

West of Savannah River Ecological Laboratory Georgia Fields SiteOperable Unit

hectare

Hazardous and Solid Waste Amendments

inch

kilometer

meter

Maximum Contaminant Level

milligramllcilogram

mile

Natioml Priorities List

operable unit

polychlorinated biphenyl

risk-based concentrations

Resource Conservation and Recovery Act, 1976

RCRA Facility Investigation

Remedial Investigation

reasonable maximum exposure

Record of Decision

Statement of Basis/Proposed Plan

South Carolina Department of Health and Environmental Control

02/08/00

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SB/PP for the West of SREL Georgia Fields Site (631 -19G) OU (U) WSRC-RP-99-4163Savannah River Site Rev. 1February 2000 Page v of vi

SCHWMRSREL

SRSSvocSWMU

US DOE

US EPA

VocWSRC

South Carolina Hazardous Waste Management Regulation

Savannah River Ecology Laboratory

Savannah River Site

semi-volatile organic constituent

solid waste management unit

a research and development designated area supporting SRSOperations; now called the Multipurpose Pilot Plant Campus

United States Department of Energy

United States Environmental Protection Agency

volatile organic constituent

Westinghouse Savannah River Company LLC

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SECTION I. INTRODUCTION ANDBACKGROUND

Introduction

This Statement of Basis/l%oposed Plan (SB/PP) is

being issued by the United States Department of

Energy (US DOE), which functions as the lead

agency for Savannah River Site (SRS) remedial

activities, with concurrence by the United States

Environmental Protection Agency (US EPA) and

the South Carolina Department of Health and

Environmental Control (SCDHEC). The purpose

of this SB/PP is to describe the preferred remedial

alternative(s) for the West of Savannah River

Ecology Laboratory (SREL) Georgia Fields Site

(63 1-19G) Operable Unit (GFS) and to provide for

public involvement in the decision-making

process. The GFS is located at the SRS in Aiken

County, South Carolina (Figure 1).

SRS manages certain waste materiaIs that are

regulated under the Resource Conservation and

Recovezy Act (RCRA), a comprehensive law

requiring responsible management of hazardous

waste. The GFS is a solid waste management unit

(SWMU) under RCRA Section 3004(u). SRS

received a RCRA hazardous waste permit from the

SCDHEC, which was most recently renewed on

September 5, 1995. Module IV of the Hazardous

and Solid Waste Amendments (HSWA) portion of

the RCRA permit mandates corrective action for

non-regulated solid waste management units

subject to RCRA 3004(u).

On December 21, 1989, SRS was included on the

National Priorities List (NPL). This inclusion

created a need to integrate the established RCRA

Facility Investigation (F@ Program witi

Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA)

requirements to provide for a focused

environmental program. In accordance with

Section 120 of CERCLA, US DOE has negotiated

a Federal Facility Agreement (FFA 1993) with US

EPA and SCDHEC to coordinate remedial

activities at SRS into one comprehensive strategy

that fulfills these dual regulatory requirements. The

FFA lists the GFS as a RCRA/CERCLA unit

requiring further evaluation using an

investigation/assessment process that integrates the

RFI process with the CERCLA Remedial

Investigation (RI) process to determine the actual

or potential impact to human health and the

environment of releases of hazardous substances to

the environment.

Both RCRA and CERCLA require that the public

be given an opportunity to review and comment on

a draft permit modification and proposed remedial

alternatives. Public participation requirements are

listed in South Carolina Hazardous Waste

Management Regulation (SCHWMR) R.61-79. 124

and Sections 113 and 117 of CERCLA. These

requirements include establishment of an

Administrative Record File that documents the

selection of remedial alternatives and allows for

review and comment by the public regarding those

alternatives (see Section 11). The Administrative

Record File must be established at or near the

facility at issue. The SRS Public Involvement Plan

(US DOE 1994) is designed to facilitate public

involvement in the decision-making process for

permitting, closure, and selection of remedial

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\-.

Figure 1.

West of SREL Georgia Fields Site and Vicinity (1951) /“\ /\\ //\\ /.+ \ /

--- /‘\\ //

Location of the West of SRELGeorgia Fields Site (63 1-19G)Operable Unit at the Savannah River

.>

Si

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alternatives. SCHWMR R.61-79. 124 and Section

117(a) of CERCLA, as amended, require

advertisement of the draft permit modification and

any proposed remedial action and provide the

public an opportunity to participate in the selection

of a remedial action. A final permit modification

will (1) include the f-l selection of remedial

alternatives under RCRA, (2) be sought for the

entire GFS, and (3) include the necessary public

involvement and regulatory approvals.

SCH WMR R.61-79. 124 requires that a brief

description and response to all significant

comments be made available to the public as part

of the RCRA Administrative Record. Community

involvement in consideration of this evaluation of

alternatives for the GFS is strongly encouraged.

All submitted comments will be reviewed and

considered. Following the public comment period,

a Responsiveness Summary will be prepared to

address issues raised during the public comment

period. The Responsiveness Summary will be

made available with the final RCRA permit and the

Record of Decision (ROD).

The final remedial decision will be made ordy after

the public comment period has ended and all the

comments have been reviewed and considered.

The fml remedial decision under RCW will be in

the form of a final permit modification decision,

which is made by SCDHEC. Selection of a

remedial alternative that will satisfy the FFA

requirements will be made by US DOE, in

consultation with US EPA and SCDHEC. It is

important to note that the f~l action(s) may be

different from the preferred alternative discussed in

this plan, depending on new information or pubIic

comments. The alternative chosen will be

protective of human health and the environment

and comply with all federal and state laws.

Background

SRS occupies approximately 310 square miles of

land adjacent to the Savannah River, principally in

Aiken and Barnwell Counties of South Carolina.

SRS is a secured U.S. Government facility with no

permanent residents. SRS is located approximately

25 miles southeast of Augusta, Georgia, and 20

miles south of Aiken, South Carolina.

SRS is owned by the US DOE. Management and

operating services are provided by Westinghouse

Savannah River Company (WSRC). SRS has

historically produced tritium, plutonium, and other

special nuclear materials for national defense.

Chemical and radioactive wastes are byproducts of

nuclear material production processes. Hazardous

substances, as defined by CERCLA, are currently

present in the environment at SRS.

SECTION II. COMMUNITYPARTICIPATION

The FFA Administrative Record File, which

contains the information pertaining to the selection

of the response action, is available at the following

locations:

U.S. Department of Energy .

Public Reading RoomGregg-Graniteville LibraryUniversity of South Carolina-Aiken171 University ParkwayAiken, South Carolina 29801(803) 641-3465

l 8&l dO 02/O /


Thomas Cooper LibraryGovernment Documents DepartmentUniversity of South CarolinaColumbia, South Carolina 29208(803) 777-4866Hard copies of the Statement of Basis/Proposed

Plan are available at the following locations:

Reese LibraryAugusta State University2500 Walton WayAugusta, Georgia 30910(706) 737-1744

Asa H. Gordon LibrarySavannah State UniversityTompkins RoadSavannah, Georgia 31404(912) 356-2183

The RCRA Administrative Record File for

SCDHEC is available for review by the public at

the following locations:

The South Carolina Department of Health andEnvironmental ControlBureau of Land and Waste Management8901 Farrow RoadColumbia, South Carolina 29203(803) 896-4000

Lower Savannah District Environmental QualityControl Office218 Beaufort Street NortheastAiken, South Carolina 29801(803) 641-7670

The public will be notified of the public comment

period through the mailings of SRS Environmental

Bulietin, a newsletter sent to citizens in South

Carolina and Georgia, and through notices in the

Aiken Standard, the AIlendale Citizen Leader, the

Augusta Chronicle, the Bamwell People-Sentinel,

and The State newspapers. The public comment

period will also be announced on local radio

stations.

US DOE will provide an opportunity for a public

meeting during the public comment period if

significant interest is expressed. The public will be

notified of the date, time, and location. At the

meeting, the proposed action will be discussed, and

questions about the action will be answered.

To request a public meeting during the public

comment period, to obtain more information

concerning this document, or to submit written

comments, contact one of the following:

Jim MooreWestinghouse Savannah River CompanyPublic InvolvementSavannah River SiteBuilding 742-AAiken, South Carolina 298081-800-249-8155jim02.moore@srs. gov

The South Carolina Department of Health andEnvironmental ControlAttn: J. T. Litton, P. E., DirectorDivision of Hazardous and Infectious WasteBureau of Land and Waste Management2600 Bull StreetColumbia, South Carolina 29201(803) 896-4000

Following the public comment period, a ROD will

be signed, and a final decision for the SRS RCRA

permit will be issued. The ROD and RCIU4 permit

will detail the remedial alternative chosen for this

OU and include responses to oral and written

comments received during the public comment

period in the Responsiveness Summary.

SECTION III. OPERABLE UNITBACKGROUND

Site History

The GFS, located approximately

north of the TNX Area (a

1.6 km (1 mi)

research and

I ouwoo

006641


development designated area supporting SRS

Operations) (see Figure 1), is approximately 0.25

ha (0.62 acre) in area. The GFS is located north of,

and adjacent to, an area formerly used by the

SREL for trapping, collecting, tagging, and

tracking of animals. A sheet metal drift fence,

approximately 76 cm (30 in) high, used by SREL

to direct small animals to collection points,

parallels the southern boundary of the site.

Presently, orange ball markers denote the boundary

of the GFS (Figure 2).

The site appears to have been used as a surface

disposal area for abandoned debris. Less than 50

percent of the unit area contains debris. Debris

located on the site includes one empty 55-gallon

steel drum, one empty 20-gallon steel drum, six

empty 5-gallon buckets, piles of burlap, wood

waste, wire coils, rolls of wire, ladders, chain link

fence parts, and miscellaneous kitchen pots and

pans. There is no evidence of past intrusive

activities at the site. In addition, the only known

construction on the site is a drift fence for which

some of the support posts remain in place. A

potential former farmhouse (pre-SRS), located just

north of the GFS, is characterized by numerous

piles of household waste (cans, bottles, etc.).

The site is heavily wooded except for an

unimproved dirt access road that crosses the

northern quarter of the site. The access road runs

east-west and then curves to the northwest; where

the road curves, what appears to be an abandoned

road splits off from the active road and continues

to the west. Most of the debris at the site is present

on either side of the abandoned road. Saplings up

to 3 cm (1.5 in) in diameter now occupy the track

of the abandoned road, suggesting that it has not

been used for some time.

There is no documentation or record of any

hazardous substance management or disposal at the

unit. Neither chemicals nor preservatives are

reported to have been used in activities performed

at the adjacent trapping area.

History of Site Investigation

The RFI/RI Work Plan with Risk Assessment for

the West of SREL Georgia Fields Site (WSRC

1999) contains the detailed information and

analytical data for all the investigations conducted

and samples taken in the media assessment of the

GFS. This document is available in the

Administrative Record File (see Section II of this

document).

Soil Investigations

Existing characterization data pertaining to the

GFS were collected during soil-gas investigations

conducted in 1988 and 1991, radiation surveys

conducted in 1990, and soil sampling

investigations conducted in 1997 and 1999. The

1997 investigations consisted of (1) discrete soil

samples collected from seven borings installed

within (next to the existing debris) and adjacent to

the GFS boundaries; and (2) four composite

surface soil samples taken from within the GFS

boundaries at random locations. Additionally,

three unit-specific background soil borings were

advanced in areas not impacted by historical

activities associated with GFS. The soil samples

were collected in surface (O to 0.3 m [0 to 1 ft])

OZ/0UC4

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SB/’PP for the West of SREL Georgia Fields Site (631 -19G) OU (U) WSRC-RP-99-4163Savannah River Site Rev. 1February 2000 Page 6 of 15

//// \\\\\\

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LEGNNL):e . . . . . . . . . . . . . . . .. PRE-UORK PLAH SOIL BMUNOSA. . . . ..> . . . . . . . . . . . . . . . . . ..PRE-UORK PM ‘3MlE■ . . . . . . . . . . . . . . . ..t999 CHLORORRM SOIL BORING—--–- . . . . . . . . . . . . . . . . . . . . . . .. LJHITWMY

. . . . . . . . . . . . . . . . . . . . . . . . . . .A~-”’”””””””’-o~A~G~ ~~~~’

N8’%H N_&$%i

- /!’,N

369220 25 50 100

Figure 2. Boundary of the West of SREL Georgia Fields Site (631 -19G) Operable Unit andLocation of Surface Samples, Soil Borings and Debris

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SB/PP for the West of SREL Georgia Fields Site (631 -19G) OU (U’) WSRC-RP-99-4163Savannah River Site Rev. 1February 2000 Page 7 of 15

below land surface (Ms), subsurface (0.3 to 1.2 m

[1 to 4 ft]) bls, and deep (>1.2 m [4 ft]) bls

intervals. The soil samples were analyzed for a

comprehensive suite of constituents including

inorganic, semi-volatile organic compounds

(SVOCS), volatile organic compounds (VOCS),

and pesticides/polychlorinated biphenyls (PCBS).

The soil-sampling investigation of 1999 was

conducted to veri~ soil-gas chloroform results

from an early soil-gas survey investigation in 1991.

T’he 1999 investigation consisted of two soil

borings sampled for chloroform only. The

sampling locations were selected to coincide with

the most contaminated soils as determined by the

1991 results. The soil samples were collected from

0.8 m (2.5 ft), 1.7 m (5.5 fl), 2.6 m (8.5 ft), 3.5 m

(11.5 tl), and 4.4 m (14.5 ft) bls. However, the

observed concentrations of chloroform were very

low (less than 0.005 mgkg) and decreased to non-

detect levels at 2.6 m (8.5 ft) bls.

Groundwater Investigation

No formal groundwater sampling has been

conducted at the unit and none is planned. The

rationale for this approach to groundwater at GFS

is presented in the following section,

Assessment Investigation Results

SoilsTwo separate soil-gas investigations were

conducted at the GFS. The fust was conducted in

March 1988 and the second in July and August

1991. The analytical results of the 1988

investigation revealed only low concentrations of

chloroform and tram- 1, 2-dichloroethene (DCE),

indicative of natural microbial degradation of

chloroform rather than a chemical release at the

site. The results of 1991 investigations also

confiied the presence of low concentrations of

chloroform. The other chlorinated hydrocarbon,

DCE, was not detected, thereby confining

microbial degra&tion rather than any chemical

spill at the site. The 1999 chloroform soil

sampling investigation also validated low (less than

0.005 mglkg) concentration levels of chloroform.

The radiation survey conducted in September 1990

did not detect any radioactive contamination at the

GFS.

The constituents of concern (COCs) associated

with the GFS soils were determined using standard

SRS risk assessment protocols for the surface,

subsurface, and deep soil exposure groups.

Contaminant migration COCS (CMCOCS) were

identified through contaminant fate and transport

analyses using a conceptual site model (CSM) to

assess the potential for adverse effects to humans

and the environment. The CSM is depicted in

Figure 3.

The results of the assessment investigations are

summarized below:

. There have been no known releases of

hazardous constituents at the GFS. Presently,

there is debris on the land surface at the unit;

however, no free liquids or mobile or highly

toxic materials are associated with the debris.

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Figure 3. Conceptual Site Model for the West of SREL Georgia Fields Site (631 -19G) Operable Unit

108dslsax~.dm OZ/07/CO

006641


●

●

●

●

●

In

The nature and extent analysis indicates that

nearly all COCs are at natural soil

concentrations and their distributions are

typical of SRS soils unimpacted by SRS

activities at the GFS.

No soil constituents exceed any applicable or

relevant and appropriate requirements

(ARARs).

No refined CMCOCS are identified; therefore,

constituents in the unit soils do not pose armigration threat to groundwater. The refined

CMCOCS are those constituents that are

retained to be further evaluated for remedial

action.

No refined human health COCS are identified;

there is negligible risk associated with the

GFS.

No ecological COCS are identified.

summary, the results of the GFS waste

characterization analyses show that no refined

COCS are associated with the GFS.

Ground water

Groundwater investigations, including collection of

groundwater samples, were not conducted at GFS.

This approach to g.roundwater was based on both

the operational history of

investigations for soil

hazardous substances are

disposed of at the GFS,

preservatives are reported

the unit and the field

contamination. No

known to have been

and no chemicals or

to have been used in

activities performed at the adjacent SREL trapping

area. This knowledge is supported by the results of

field investigations and soil sampling conducted in

1997 and 1999, which showed no sign of

hazardous waste disposal at this unit. In addition,

contaminant fate and transport analysis did not

predict Mure migration of GFS soil constituents to

the groundwater. Therefore, there is no indication

that groundwater impacts from past activities at the

GFS have ever occurred or are likely to occur in

the i%ture.

Removal Action

No hazardous substances are known to have been

disposed of at the GFS and no chemicals or

preservatives are reported to have been used in

activities performed at the adjacent trapping area.

The original contents of the empty drums and

buckets that form apart of the debris located on the

unit cannot be identified and the exact disposal

dates are unknown. No removal action of any kind

has taken place at the unit.

Site Characteristics

Physical Features

The GFS is a heavily wooded site except for an

unimproved dirt access road (shown in Figure 2).

The vegetation is dominated by second growth

mixed hardwoods including sweet gum, live oak,

scrub oaks, American e~ and hickories. A few

pine trees are also present at the GFS, forming a

dense canopy over a relatively open understory.

The underbrush includes Carolina Creeper and

poison ivy. The ground cover consists of fallen

deciduous tree leaves and pine needles.

The ground surface is generally flat, sloping gently

(2-to-3-percent slope) to the north-northwest.

North of the unit, the grade increases to 8 to IO

percent and then flattens out into the floodplain of

1 ot16cleamwpda 0210wxl


Upper Three Runs Creek. There are no distinct

surface depressions or surface water drainage

features.

A manmade gully, approximately 6 m (20 t?)

across and 1.8 m (6 ft) deep, is located 50 m

(160 ft) north of the unit. The gully feeds into the

Upper Three Runs Creek floodplain, which is

approximately 300 m (1400 t?) north of the unit.

There exists no wetland and no water well that can

be used as a drinking water source.

No threatened or endangered and sensitive species

exist in the vicinity of the GFS.

Waste Characteristics

Field investigations and soil-gas surveys conducted

at the GFS found no evidence of any surface or

buried hazardous material at the unit. Most of the

debris located on the site is on the land surface, and

no free liquids or mobile or highly toxic materials

are associated with the debris. Therefore, no

principal threat source material is present at the

unit.

Public Participation

There has been no public participation associated

with the GFS prior to the issuance of this SB/PP.

SECTION IV. SCOPE AND ROLE OFOPEIUBLE UNIT OR RESPONSE ACTION

The overall strategy for addressing the GFS was to

(1) characterize the waste unit, delineating the

nature and extent of contamination and identifying

the media of concern (penform the RFURI); (2)

perform a baseline risk assessment (BR4) to

evaluate media of concern, COCS, exposure

pathways, and characterize potential risks; and (3)

evaluate and perform a final action to remediate, as

needed, the identified media of concern.

The GFS is an OU located with- the Upper Three

Runs Creek Watershed that is not a “source

control” unit (i.e., the unit does not contain

contaminated soil that may act as a source of fiture

contamination to the groundwater through

leaching). In addition to the GFS unit, there are

m~y OUS within the watershed. All the source

control and groundwater OUS located within the

watershed will be evaluated to determine their

impacts, if any, to the associated streams and

wetlands.

SRS will manage all source control units to prevent

impact to the watershed. Upon disposition of all

source control and groundwater OUS within the

watershed, a final comprehensive ROD for the

Upper Three Runs Watershed will be pursued.

The previous field investigations and soil sampling

conducted in 1997 and 1999 during the

development of the RFI/RI Work Plan for the GFS

(WSRC 1999) have indicated that the groundwater

has not been impacted by the GFS. The results of

the contaminant fate and transport analysis also did

not reveal any potential for impact to the

groundwater. The groundwater does not outcrop in

the vicinity of the GFS.

The risk assessments have also revealed that there

is negligible risk ‘to human health and the

environment associated with the GFS. There is no

principal threat source material present at the unit

and, therefore, the GFS requires no cleanup

activities. Hence, a No Action alternative is

recommended for the unit. This means no fiuther

l &5 k ’ dO 02/

006641


action will be taken and the GFS will remain in its

present condition. Therefore, the GFS will have no

impact on the response actions of other OUs at

SRS.

SECTION V. SUMMARY OF SITE RISKS

As a component of the RFURI process, a BRA was

performed for the GFS. The BIU4 included human

health risk and ecological risk assessments.

The results of the risk assessments are summarized

in the following paragraphs.

Summary of the Human Health RiskAssessment

A review of the analytical data contained in the

RFI/RI Work Plan for the GFS (WSRC 1999)

indicates that the &ta are of sufficient quality for

use in the risk assessment evaluation.

Based on the existing analytical data, an evaluation

was conducted to estimate the human health and

environmental problems that could result from the

current physical and waste characteristics of the

GFS. The results of the assessment indicated that

the concentrations of all the constituents analyzed

(except for arsenic and antimony) were below US

EPA risk-based concentrations (RBCS) and the

calculated risks were below the US EPA target risk

range of 1.0 x 104 to 1.0 x 10<. The

concentrations of arsenic and antimony were above

RBCS and carried forward as COCS. Antimony and

arsenic were identified as COCS for the residential

receptors but were not earned forward as refined

COCS because the unit concentrations were within

the range of concentrations expected in SRS

background soil conditions. Hence, there are no

refined human health COCS, and no health risks

are posed by the GFS soils and groundwater to

current or fhture workers and fiture residents at the

unit that warrant remedial action.

Summary of Ecological Risk Assessment

The purpose of the ecological risk assessment

component of the BRA is to evaluate the likelihood

that adverse ecological effects may occur or are

occurring as a result of exposure to unit-related

constituents based on a line-of-evidence approach.

Based on the analytical data pertaining to the GFS,

there is no compelling evidence that hazardous

materials were managed or disposed of at this unit.

The ecological risk assessment has also concluded

that no refined COCS are associated with the GFS,

and therefore the unit poses a negligible risk to the

ecological receptors.

Summary of Contaminant Fate and TransportAnalysis

The CSM used for the analysis of contaminant fate

and transport is presented in Figure 3. The

analysis was based on the data collected from 1997

and 1999 soil sampling investigations. The results

of the CSM reveal that the concentrations of

constituents detected in the GFS soils will not

exceed their Maximum Contaminant Levels

(MCLS) within the 1,000-year modeling period.

MCL is the maximum concentration of a substance

allowed in water that is delivered to any user of a

public water supply as required by the Safe

Drinking Water Act. The CSM identified no

refined CMCOCS. Therefore, the GFS soils do not

pose a migration threat to groundwater.

Iomclcamrwp.dm Oz/os/oo

SB/PP for the West of SREL Georgia Fields Site (631-19G) OU (U) WSRC-RP-99-4163Savannah River Site Rev. 1February 2000 Page 12 of 15

Risk Assessment Summary

The risk assessments and contaminant fate and

transport analysis establish that the risk associated

with the GFS is negligible, and the field

investigations do not establish any known release

of hazardous constituents at the GFS. From this, it

can reasonably be concluded that no principal

threat source material exists at the unit. There is

only debris on the land surface at the unit and no

mobile or highly toxic materials are associated

with the debris. Therefore, no remedial action is

necessary at the GFS to ensure protection of

human health and the environment.

SECTION VL REMEDIATIONOBJECTIVES

Based on the characterization and risk assessment,

the GFS poses negligible risk to human health and

the environment. No refined COCS are identified

as human health COCS, ecological COCS, or

CMCOCS. No soil constituent exceeds ARM&

Therefore, a No Action alternative is identified as

the preferred remedial alternative. Since no

refined COCS are identified for the .GFS, no

remedial action objectives were developed and no

remediation goals were established.

SECTION VII. SUMMARY OFALTERNATIVES

Based on the unit characterization data and risk

assessment results, there is negligible risk

associated with the GFS. For this reason, a No

Action alternative is identified as the preferred

remedial alternative. No other alternatives were

developed for consideration and evaluation.

SECTION VIII. EVALUATION OFALTERNATIVES

According to US EPA guidance, if there is no

current or potential threat to human health and the

environment and no action is warranted, the

CERCLA 121 requirements are not triggered. This

means that there is no need to evaluate other

cleanup alternatives or to evaluate the No Action

alternative against the nine remedy selection

criteria under CERCLA. These nine criteria are

used as a basis for selecting cleanup remedies that

are protective of human health and the

environment implementable, cost-effective, and

acceptable to the State regulatory agency.

The No Action alternative will be the final action

for the GFS. This alternative will provide

protection to human health and the environment at

the GFS.

This SB/PP provides for community involvement

through a document review process and a public

comment period. Public input will be documented

in the Responsiveness Summary section of the

ROD.

SECTION IX. PREFERREDALTERNATIVE

The No Action alternative is the preferred

alternative for the GFS. This means that no

remedial action will be performed at the GFS.

There is no waste to trea~ no institutional or

engineering controls are required, and there are no

ARARs. Because no timber action will be taken,

the GFS will remain in its present condition.

No capital andlor operation and maintenance costs

will be involved for this action.


The preferred alternative can change in response to

public comment or new information.

SECTION X. POST-ROD SCHEDULE

No remedial action will be performed at the GFS;

therefore, a schedule for post-ROD cleanup

activities is not provided.

The ROD for the GFS will be drafted after receipt

of, and response to, public and regulatory

comments on this Statement of Basi@roposed

Plan. The Revision O ROD is scheduled for

submittal to US EPA and SCDHEC for review in

June 2000. The final ROD, which responds to

regulatory agency comments, is scheduled for

submittal in September 2000.

REFERENCES

DOE (US Department of Energy), 1994. Public

Involvement, A Plan for the Savannah River Site,

Savannah River Operations OffIce, AikerL SC.

Federal Facility Agreement, 1993. Federal Facility

Agreement for the Savannah River Site,

Administrative Docket No. 89-05-FF (Effective

Date: August 16, 1993).

WSRC, 1999. RCRA InvestigationlRemedial

Investigation Work Plan with Risk Assessment for

the West of SREL Georgia Fielak Site (631 -19G),

WSRC-RP-98-4054, Rev. 1.1, Westinghouse

Savannah River Company, Aiken, SC.

GLOSSARY

Administrative Record File: A file that is

maintained and contains all information used to

make a decision on the selection of a response

action under the Comprehensive Environmental

Response, Compensation, and Liability Act. This

file is to be available for public review, and a copy

is to be established at or near the Site, usually at

one of the information repositories. Also a

duplicate file is held in a central location, such as a

regional or state oftice.

ARARs: Applicable, or Relevant and Appropriate

Requirements. Refers to the federal and state

requirements that a selected remedy will attain.

These requirements may vary from site to site.

Baseline Risk Assessment: Analysis of the

potential adverse health effects (current or future)

caused by hazardous substance release from a site

in the absence of any actions to control or mitigate

these releases.

Characterization: The compilation of all

available data about the waste units to determine

the rate and extent of contaminant t migration

resulting from the waste site, and the concentration

of any contaminants that maybe present.

Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA),

1980: A federal law passed in 1980 and modified

in 1986 by the Superfund Amendments and

Reauthorization Act. The act created a special tax

that goes into a trust fired, commonly known as

Superfimd to investigate and clean up abandoned

or uncontrolled hazardous waste sites.

Corrective Action: A US EPA requirement to

conduct remedial procedures under RCIM 3998(h)

at a facility when there has been a release of

hazardous waste or constituents into the

environment. Corrective action may be required

beyond the facility boundary and can be required

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SB/PP for the Weat of SREL Georgia Fields Site (631 -19G) OU (U) WSRC-RP-99-4163Savannah River Site Rev. 1February 2000 Page 14 of 15

regardless of when the waste was placed at the

facility.

Exposure: Contact of an organism with a

chemical or physical agent. Exposure is quantified

as the amount of the agent available at the

exchange boundaries of the organism (e.g., slciw

lungs, digestive tract etc.) and available for

absorption.

Federal Facility Agreement (FFA): The legally

binding agreement between regulatory agencies

(US EPA and SCDHEC) and regulated entities (US

DOE) that seta the standards and schedules for the

comprehensive remediation of the SRS.

Media: A pathway through which contaminants

are transferred. Five media by which contaminants

may be transferred are groundwater, soil, surface

water, sediments, and air.

National Priorities List (NPL): US EPA’s formal

list of the nation’s most serious uncontrolled or

abandoned waste sites, identified for possible long-

term remedial response, as established by

CERCLA.

Operable Unit (OU): A discrete action taken as

one part of an overall site cleanup. The term is

also used in US EPA guidance documents to refer

to distinct geographic areas or media-specific units

within a site. A number of operable units can be

used in the course of a cleanup.

Operation and Maintenance (O&M): Activities

conducted at a site after a response action occurs to

ensure that the cleanup and/or systems are

fimctioning properly.

Overall Protection of Human Health and the

Environment: The assessment against this

criterion describes how the alternative, as a whole,

achieves and maintains protection of human health

and the environment.

Principal Threat Source Material (PTSM_):

Generally, those source materials considered to be

highly toxic or highly mobile which generally

cafiot be contained in a reliable manner or would

present a significant risk to human health or the

environment should exposure occur.

Proposed Plan (PP): A legal document that

provides a brief analysis of remedial alternatives

under consideration for the site/operable unit and

proposes the preferred alternative. It actively

solicits public review and comment on all

alternatives under consideration.

Reasonable Maximum Exposure (RME): This is

the value below which the average concentration

will fall 95 percent of the time.

Record of Decision (ROD): A legal document

that explains to the public which alternative will be

used at a siteloperable unit. .The record of decision

is based on information and technical analysis

generated during the remedial investigatiord

feasibility study and consideration of public

comments and community concerns.

Resource Conservation and Recovery Act

(RCRA), 1976: A federal law that established a

regulatory system to track hazardous substances

from their generation to disposal. The law requires

safe and secure procedures to be used in treating,

transporting, storing, and disposing of hazardous

1 Owclcamcntpcla 020wo

006641


substances.

creation of

sites.

RCIL4 is designed to prevent the

new, uncontrolled hazardous waste

Responsiveness Summary: A summary of oral

and/or written comments received during the

proposed plan comment period including

responses to those comments. The Responsiveness

Summary is a key part of the ROD, highlighting

community concerns.

Statement of Basis (SB): A report describing the

corrective measureshemedial actions being

conducted pursuant to South Carolina Hazardous

Waste Management Regulations, as amended.

Super fund: The common name used for

CERCLA; also referred to as the Trust Fund. The

Superfimd program was established to help fired

cleanup of hazardous waste sites. It also allows for

legal action to force those responsible for the sites

to clean them up.

Target Risk Range: US EPA guidance for

carcinogenic risk due to exposure to a known or

suspected carcinogen between one excess cancer in

an exposed population often thousand (1.0 x 104)

and one excess cancer in an exposed population of

one million (1.0 x 104). Risks within this range

require risk management evaluation of remedial

action alternatives to determine if risks can be

reduced below one excess cancer in a million

(1.0 x 10<). Risks greater than 1.0x 104 indicate

that remedial action is generally warranted.

1086cleancwni0c LWOWO

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